Revisional power does not revive a final assessment; reassessment for escaped turnover must still meet the statutory limitation period.

A revisional order under section 21 was held to be supervisory and did not keep a completed assessment pending or destroy its finality after the appeal stage had ended. As the assessment had already become final, any action to tax escaped turnover had to comply with section 11-A. A fresh assessment initiated after the expiry of four years from the end of the accounting year was therefore barred by limitation and without jurisdiction. The remand did not enlarge the Assessing Authority's power to override the statutory time bar, and the impugned reassessment was quashed.

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Issues: (i) Whether an assessment that had become final was kept alive by the Commissioner's revisional order under section 21 so as to exclude the case from the rule against escapement of turnover. (ii) Whether a fresh assessment made after the expiry of four years from the end of the accounting year was without jurisdiction under section 11-A.

Issue (i): Whether an assessment that had become final was kept alive by the Commissioner's revisional order under section 21 so as to exclude the case from the rule against escapement of turnover.

Analysis: The revisional power under section 21 was held to be supervisory in nature. It enabled the Commissioner to examine legality or propriety of orders already made, but it did not suspend or destroy the finality of an assessment once the stage of appeal had passed. The assessment in question had been completed and tax had been paid, so the subsequent revisional interference operated on a final order and did not convert the matter into a continuing assessment proceeding.

Conclusion: The assessment remained final despite the revisional order, and the proceedings initiated later could not be treated as pending assessment proceedings.

Issue (ii): Whether a fresh assessment made after the expiry of four years from the end of the accounting year was without jurisdiction under section 11-A.

Analysis: Once the original assessment was treated as final, any attempt to bring to tax turnover said to have escaped assessment had to conform to section 11-A. The fresh assessment was initiated beyond the prescribed period of four years. The limitation applicable to escaped assessment therefore controlled the action of the Assessing Authority, and the order made after that period could not be sustained. The scope of remand did not enlarge the authority of the Assessing Authority to bypass the statutory time bar.

Conclusion: The fresh assessment was barred by limitation and was without jurisdiction.

Final Conclusion: The impugned assessment was quashed because the reassessment was initiated after the statutory period had expired and the revisional order did not prevent the earlier assessment from attaining finality.

Ratio Decidendi: A revisional order does not keep a completed assessment pending for all purposes; once the assessment is final, any reassessment for escaped turnover must be initiated within the period prescribed by the governing limitation provision.

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